People v. Williams
2017 IL App (1st) 142733
| Ill. App. Ct. | 2018Background
- Five people were shot to death at a Chicago residence on April 22, 2008; Torolan Williams was arrested on June 9, 2008 and later tried for five counts of first‑degree murder and one count of armed robbery.
- While in custody, Williams repeatedly asked to make phone calls (to check on his newborn son); his requests were denied multiple times before he made inculpatory statements and later invoked counsel at 6:28 p.m.; the court suppressed statements made after the invocation and those at the hospital where counsel was denied access.
- The State introduced cooperating witness Arthur Brown’s testimony that Williams acted as a lookout and handled stolen goods, supported by cell‑phone company call detail records and an FBI agent’s mapping of which cell towers were used that night.
- Williams moved for suppression of his statements (coercion/denied phone access) and for a Frye hearing on the cell‑tower evidence; the trial court denied suppression in part and denied a Frye hearing; Williams was convicted and sentenced to life for each murder and 20 years for robbery.
- On appeal Williams challenged: voluntariness of pre‑counsel statements (statutory and constitutional), denial of a Frye hearing for historical cell‑site data, prejudicial sentencing discussion in an interrogation video and alleged breaches of the court’s pretrial limits on cell‑site argument, and the judge’s reference to some verdict forms as “guilty forms.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Voluntariness of statements before invocation of counsel | Statements were voluntary; Miranda warnings given repeatedly; totality supports admissibility | Denial of phone calls and his emotional state rendered statements involuntary and violated 725 ILCS 5/103‑3 | Court: statements before counsel were voluntary; denial of calls did not overbear will; no statutory remedy but not coercive here |
| Frye hearing for cell‑site/tower evidence | Cell‑site mapping is not novel scientific technique; no Frye required; agent may testify as to towers used | Cell‑site plotting is novel and requires Frye reliability vetting | Court: Frye not required; plotting tower IDs on a map is not novel science; accuracy/weight go to credibility |
| Sentencing discussion in interrogation video | Not material to guilt; trial court admonished jury; no prejudice | Inclusion of ASA/defendant exchange about death penalty prejudiced jury | Court: admission was improper but not materially prejudicial; trial court admonitions and lack of sentencing argument cured error |
| State’s closing comments allegedly violating pretrial cell‑site ruling | Arguments merely applied admitted cell‑site evidence to corroborate testimony | State exceeded pretrial limits and misled jury with tower inferences | Court: issue waived (no contemporaneous objection or posttrial motion); cannot review on appeal |
| Judge referring to some verdict forms as “guilty forms” during instructions | N/A (prosecution) | Misstatement showed judicial partiality and prejudiced jury | Court: slip of phrase not plain error given full, correct instructions (presumption, burden, elements); no reversal |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishes Miranda warnings for custodial interrogation)
- Jackson v. Denno, 378 U.S. 368 (involuntary confessions and due process suppression rules)
- Haynes v. Washington, 373 U.S. 503 (coercion/incommunicado detention can render confession involuntary)
- Frye v. United States, 293 F. 1013 (D.C. Cir.) (old standard for general acceptance of novel scientific techniques)
- Donaldson v. Central Illinois Public Service Co., 199 Ill. 2d 63 (judicial notice of general acceptance; Frye framework)
- In re Commitment of Simons, 213 Ill. 2d 523 (Frye analysis for novel scientific evidence)
- People v. McKown, 236 Ill. 2d 278 (Frye/general‑acceptance principles in Illinois)
- People v. Gilliam, 172 Ill. 2d 484 (voluntariness test for confessions)
- People v. Richardson, 234 Ill. 2d 233 (totality of circumstances for voluntariness)
- People v. Piatkowski, 225 Ill. 2d 551 (plain error/Rule 451(c) regarding instruction defects)